The process that elects new members into the Pro Football Hall of Fame is both subjective and restrictive. It is presided over by a Board of Selectors consisting of media members throughout the country. These 40 men essentially serve as judge and jury, with their votes determining each individual's fate. Bylaws mandate an 80-percent approval (32 votes), and the maximum class size for induction is six.

A year ago, the Cold, Hard Football Facts felt compelled to plead the cases of three overlooked players – Ken Anderson, Harold Carmichael and Andre Tippett. Each man has repeatedly been a victim of the system, unjustly denied entry into the Hall despite reputations as outstanding performers and upstanding citizens.

With the Class of 2006 gathering in Canton, Ohio, for Saturday's enshrinement ceremony, we must now move to the other side of the crowded courtroom of public opinion. Our position is simple: Warren Moon does not belong as a first-ballot inductee.

The true measure of a man's greatness is his performance when it matters most. NFL quarterbacks are largely defined by how they play in the postseason, and those who compete for – and win – championships are held in the highest regard.

In the modern era, 12 quarterbacks have reached the Hall of Fame in their first year of eligibility. The chart below shows how they fared in the postseason:

Quarterback (Year)

Team(s)

Playoff Record

Pct.

Bart Starr (1977)

Packers

9-1

.900

Johnny Unitas (1979)

Colts, Chargers

6-2

.750

Roger Staubach (1985)

Cowboys

11-6

.647

Terry Bradshaw (1989)

Steelers

14-5

.737

Dan Fouts (1993)

Chargers

3-4

.429

Joe Montana (2000)

49ers, Chiefs

16-7

.696

Jim Kelly (2002)

Bills

9-8

.529

John Elway (2004)

Broncos

14-7

.667

Dan Marino (2005)

Dolphins

8-10

.444

Steve Young (2005)

Buccaneers, 49ers

8-6

.571

Troy Aikman (2006)

Cowboys

11-4

.733

Warren Moon (2006)

Oilers, Vikings, Seahawks, Chiefs

3-7

.300

Moon has by far the worst playoff winning percentage of any first-ballot quarterback. His most memorable moment arguably came in 1992's wild-card round, when Houston suffered the indignity of the largest blown lead in NFL history. Behind second-string QB Frank Reich, the Bills rallied from a 32-point deficit to beat the Oilers in overtime, 41-38. A crucial Moon interception early in the extra session set up the game-winning field goal.

Point 2: No championship appearances

In a related argument, Moon's postseason futility went beyond just a poor career record. If his three victories (or even two of them) had been part of a single playoff run, he might have been viewed differently. But Moon never won more than one game in any postseason. Not only did he fail to reach a Super Bowl – he never even advanced to a conference championship.

While two other quarterbacks on the list – Marino and Fouts – had losing postseason records, both of them made multiple appearances in AFC championship games. And with the exception of Fouts, every QB previously inducted on the first ballot had been to at least one Super Bowl. Seven of the 11 won multiple NFL championships. Here is how the bottom three stack up:

Marino: 3 conference championships, 1 Super Bowl

Fouts: 2 conference championships, 0 Super Bowls

Moon: 0 conference championships, 0 Super Bowls

Point 3: Product of pass-happy offenses

Yes, Moon's regular-season stats are impressive. He currently ranks fourth all-time in attempts (6,823), completions (3,988) and yards (49,325) and fifth in touchdown passes (291). The sheer volume of those numbers merits Hall of Fame consideration.

But Moon benefited greatly from playing for many years in the run-and-shoot offense. It was predicated on a wide-open passing attack, and he generally had at least four receivers from which to choose. Almost any quarterback would be productive under that system. During that '92 season, for instance, backup Cody Carlson started six games after Moon got injured. The unheralded Carlson passed for 1,710 yards and nine touchdowns.

Point 4: CFL stats don't matter

Moon had a remarkable six-year career in the Canadian Football League, but it needs to be put into perspective. He was playing against inferior competition in a nine-team league. Wondering what would have happened if he had gone straight to the NFL is pointless, because no team was remotely interested in him until he refined his passing skills up there.

Moon is also frequently credited with guiding the Edmonton Eskimos to five consecutive Grey Cup victories between 1978 and 1982. In fact, the primary quarterback during the first two of those seasons was a gentleman named Tom Wilkinson.

Furthermore, no player has ever been enshrined in Canton for his success in the CFL, WFL, USFL, XFL or Arena League. While the building may be called the Pro Football Hall of Fame, it really only recognizes NFL contributions. Gridiron historians will remember that the league was called the American Professional Football Association when it was founded in 1920, and the NFL merged with the rival AFL in 1970.

Point 5: Fumbling machine

Moon was easily the most prolific fumbler that the game has ever seen. He possesses the NFL record for career fumbles with 161. He twice had more fumbles in a season than games played (18 in 1990, 17 in 1984).

And Moon's problems with hanging onto the pigskin weren't limited to the regular season. He also holds the postseason mark with 16 career fumbles – in just 10 games. During a divisional playoff against Kansas City on Jan. 16, 1994, he fumbled a mind-boggling and record-setting five times. Not surprisingly, the Oilers ended up losing to the Chiefs, 28-20.

Point 6: Character issues

Although the Pro Football Hall of Fame doesn't officially have a "morals clause" like its baseball counterpart does, character is sometimes taken into account by the board. For example, most people would argue that the candidacy of Cowboys receiver Michael Irvin has been hurt by his drug-related arrests.

A pair of 1995 incidents should likewise have weighed against Moon. First, he reached an out-of court settlement with a former Vikings cheerleader who alleged that the quarterback had harassed her and forced her to have sex with him. Moon was married and had four children at the time.

Then, according to police in Missouri City, Texas, Moon allegedly struck his wife Felicia in the head and choked her to the point that she was nearly unconscious. He fought the charges of assault in a subsequent jury trial and was acquitted after Felicia told a different story than she had originally. She testified that the argument was her fault and that her injuries may have been self-inflicted.

Judging by Warren's postseason play, wrapping both hands tightly around your own neck must be a Moon family trademark.

The majority of the 40 Hall of Fame voters evidently turned a blind eye to Warren Moon's shortcomings and transgressions. In his case, however, the all-seeing Cold, Hard Football Facts should have tipped the scales of justice. A preponderance of evidence shows that Moon did not deserve to be a first-ballot inductee.